IRS Allows HDHPs to Pay for COVID-19 Tests and Treatment

On March 11, 2020, the Internal Revenue Service (IRS) issued Notice 2020-15, which allows high deductible health plans (HDHPs) to pay for COVID-19 testing and treatment without a deductible. This also means that an individual with an HDHP that covers these costs may continue to contribute to a health savings account (HSA).


  • As a growing trend, many states are directing or encouraging health insurance issuers to cover COVID-19 testing and treatment without any cost sharing.
  • The IRS is now allowing HDHPs to pay for this testing and treatment before the plan's deductible is met.
  • Individuals with HDHPs that cover this testing and treatment without cost sharing can still make HSA contributions.
  • The IRS also noted that, as in the past, any vaccination costs continue to count as preventive care and can be paid for by an HDHP.

Action Steps

  • Employers with HDHPs should check with their plan's issuer or benefits administrator regarding their plan's coverage for COVID-19 testing and treatment.


We will continue to monitor updates from the Centers for Disease Control and the World Health Organization and will continue to seek guidance from these agencies and public health officials, and provide updates as necessary.

If you have questions related to this update, please contact your North Risk Partners advisor. Don’t have an advisor? No problem. We’ll help you find one.

This regulatory update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.